Beware Sucker's Rally in RIMM, Nokia

Shares of second-tier cell phone makers are up sharply, but it looks like a "Palm rally."

Research in Motion (ticker: RIMM) shares have roughly doubled in three months. Nokia (NOK) has doubled in five months. An investor who believes turnarounds are afoot for both companies would also have to believe there is room for at least four major smartphone platforms: thriving iOS from Apple (AAPL) and Android from Google (GOOG); Microsoft's new Windows Phone 8, which Nokia is betting its future on; and BlackBerry 10, a long-awaited upgrade from RIMM expected in January.